Statutory overpayment-interest limits apply in the savings-bond context

Number
202139008
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Interest on State and Local Bonds (Formerly Interest on Certain Governmental Obligations)
Code sections
§ 103, § 6611
Ruling dated
August 6, 2021
Publicly released
October 1, 2021

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This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2021, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel addressed interest in connection with the purchase of U.S. Series I savings bonds through Form 8888. The brief email states that, in the bond context, the listed provisions of Section 6611 apply when their conditions are met. Those provisions would prohibit or limit payment of interest as described in the statute. The released text does not provide further facts or analysis.

Ruling snapshot

  • Question: Do specified Section 6611 limits on interest payments apply in the savings-bond context?
  • Outcome: Advice given, the provisions prohibit or limit interest when applicable
  • Key authorities: IRC § 6611(b)(3), (e)(1), (e)(3), and (g)

Full text (IRS public release)

ID:      CCA_2021080609590950
UILC:    103.00-00

Number: 202139008
Release Date: 10/1/2021
From: ---------------------
Sent: Friday, August 6, 2021 9:59:09 AM
To: --------------------
Cc:
Bcc:
Subject: RE: Form 8888 & Interest on Purchase of U.S. Series I Savings Bonds


[-------and I are in agreement that in the bond context, when these provisions
[6611(b)(3), (e)(1), (e)(3), and (g)] are applicable, they would prohibit or limit payment of
interest as described in the statute
]

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